PACIFIC INTERPRETERS' PRIVACY POLICY

PRIVACY POLICY

At Pacific Interpreters, a LanguageLine Solutions® company, we recognize the importance of privacy to our customers and employees and we make it a top priority to safeguard the personal information we collect.

The purpose of this Privacy Policy and Safe Harbor Framework (this “Policy”) is to describe the practices employed by Pacific Interpreters with respect to the acquisition, receipt, use, and protection of the information we receive from and on behalf of our customers, and visitors to our website located in the European Union (“EU”) or outside the EU.

ADHERENCE TO THE SAFE HARBOR PRINCIPLES

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the “Safe Harbor Principles”) to enable U.S. companies to satisfy the EU law requirement that personal information transferred from the EU to the United States be adequately protected. Consistent with its pledge to protect personal privacy,

Pacific Interpreters complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Pacific Interpreters has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Pacific Interpreters’ certification, please visit http://www.export.gov/safeharbor/. Pacific Interpreters has chosen the EU DPA to serve as an independent resource mechanism (IRM) for dispute resolution.

SCOPE OF THIS POLICY

This Policy applies to all personal information received by Pacific Interpreters through its website and otherwise, including from the EU.

INFORMATION COLLECTED AND MANNER USED

Pacific Interpreters may collect information in the following ways:

If you visit our website http://www.pacificinterpreters.com/ you can order certain services online (Personal Interpretation, Document Translation and LanguageLine Academy services) using a credit card. We and our third party E-commerce provider collect basic information including your name, credit card type and number (and security code), billing address, email address, and telephone number. This information is used by us for internal purposes only in setting up account information, processing your request and billing you for services requested. All of this information is stored on secure servers and is never disclosed to third parties.

As is true of most websites, when you visit our website, we may collect non-personally identifiable information such as the type of browser and computer operating system you use, and the domain name of your Internet service provider (ISP). We collect and use this non-personally identifiable information to learn more about our website’s visitors in general, and how to supply more appropriate information to them.

We also may request the following types of personally identifiable information: name, address, e-mail address, telephone number, fax number, credit card information, and information about your interests in and use of various products and services. Whenever we request the identity of a visitor, we will clearly indicate the purpose of the inquiry before the information is requested.

We distribute e-mail only to persons or organizations who have explicitly requested it, or with which we have a pre-existing personal or business relationship that can be verified. We consider customer purchases and requests for information as valid connections for e-mail correspondence.

We maintain a strict “No-Spam” policy. We do not sell, rent, or otherwise give your e-mail address to any third party organization. Pacific Interpreters complies with the CAN-SPAM Federal Law.

As added insurance of your privacy, we have a relationship with an independent, third party company that sends e-mail announcements on our behalf to individuals who request them. When you subscribe to our e-mail newsletter your personally identifiable information will never be used by Pacific Interpreters for any purposes other than to deliver e-mail to you. You may stop the arrival of e-mail at any time by completing the request form on our website or by following the instructions on the e-mails you receive.

We do not record or store any information during over-the-phone interpreting calls. All of our over the phone calling sessions are in compliance with the security requirements of federal and state laws such as the Health Insurance Portability and Accountability Act, the Right to Financial Privacy Act, and the Gramm-Leach-Bliley Act.

DATA INTEGRITY

Pacific Interpreters employs state of the art measures to protect customer information from loss, misuse, unauthorized access, disclosure, alteration and destruction of information which includes compliance with confidentiality and non-disclosure provisions in agreements between Pacific Interpreters and its customers, affiliates, suppliers, and employees.

Pacific Interpreters maintains customer information on secure servers located in secure data centers. Personal information stored in databases requires unique login ids and passwords in order to access the information and is only used for the intent described in this policy. All access to personal

information and other customer data is controlled and monitored by Pacific Interpreters’ full time IT staff. All servers are protected by one or more firewalls restricting access to the individuals for which access is specifically intended. Extensive monitoring and security tools are utilized to ensure confidentiality, integrity, and availability.

ACCESS TO PERSONAL INFORMATION

If you have provided us with personal information and that information changes, or if you terminate the services you ordered through our website, you may update, delete or request a copy of any information we maintain about you by contacting us at One Lower Ragsdale Drive, Monterey CA 93940 Att: Chief Compliance Officer.

CHANGES IN THIS PRIVACY STATEMENT

If we decide to change our privacy policy, the changes will be posted on our website and distributed to any organizations that maintain this information, such as the US Department of Commerce.

COPA AND CHILDREN’S ISSUES

The Website is not directed to children under thirteen (13) years of age, and children under such age must not use the website or services offered on it for any purpose, including to submit any individually identifiable information about themselves.

ENFORCEMENT

Pacific Interpreters uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Safe Harbor Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using an independent resource mechanism as a third party resolution provider.